SCAQMD Set to Overhaul Coatings Rules

VOC averaging will end, VOC limits on colorants will begin, and rules on packaging, purchasing and storing coatings will change under an impending overhaul of the South Coast Air Quality Management District’s venerable Rule 1113.

SCAQMD is considered one of the nation’s most stringent regulatory bodies on paint and coatings emissions. Rule 1113, established in 1977, regulates VOC content of architectural coatings, which includes bridge, roadway, pavement and roof coatings.

The latest draft of the changes, dated Jan.12, 2011, includes several new VOC limits that largely reflect current coatings technology, first-time VOC limits on colorants, explicit clarification of the coatings categories covered, and a weight limit on ozone-depleting materials.

The rule also expands covered coatings transactions to include purchases made through third parties like Amazon and eBay.

SCAQMD officials have been working for several years with paint and coatings manufacturers, retailers, colorant manufacturers and coatings equipment manufacturers on the rules, and those dialogues will continue until the measure comes to a vote April 1, said Naveen Berry, planning and rules manager.

“They’ve worked with us very closely and have been very helpful in refining the process in terms of realistic implementation dates” and other expertise, Berry said.

These will be the most extensive changes to the rules since 2006.

The End of Averaging

One key change in the rules would be the phase-out of the VOC Averaging Compliance Option, first established in 1996. VOC limits and averaging have declined so much over the years that the option no longer seems necessary—and can be anti-competitive when it ends up allowing the use of an unusually high-VOC, lower-cost product, said Berry.

Only six manufacturers use the averaging option today, compared with 12 a few years ago. Beginning Jan. 1, 2012, primers, sealers, undercoaters and specialty primers will no longer be eligible for averaging.

Effective July 1, 2012, only rust preventative coatings, stains, industrial maintenance coatings and a few other products may be averaged.

VOC Reductions

The new rule will reduce VOC limits in several types of products, including:

• Sacrificial Anti-Graffiti Coatings, which now have a limit of 100 g/L, will be reduced to 50 g/L. (Non-sacrificial anti-graffiti coatings will remain at 100 g/L.)

• Form Release Compounds, now limited to 250 g/L, will be limited to 100 g/L.

• Fire-Proofing Coatings, now limited to 350 g/L, will be reduced to 150 g/L.

• Primers, Specialty Primers, Sealers and Undercoaters, now limited to 100 g/L, will be reduced to 50 g/L.

• Concrete Surface Retarders, now limited to 250 g/L, will be limited to 50 g/L.

Colorant VOCs

Another change will be the establishment of VOC limits on colorants. Many current base coats meet low- and zero-VOC guidelines, but colorants—particularly those used to produce today’s bold colors—can ratchet up the tinted coating content to 100 g/L.

Europe has limited VOC content on colorants for several years, and most major U.S. manufacturers are already producing a low-VOC colorant, Berry said.

In fact, he said, most of the coatings products currently being produced already comply with the new VOC limits. For some categories, every product now available meets the new limit; for a few, more than half of the available products already comply.

The district had initially proposed some lower VOC limits but raised them after feedback from the coatings industry.

Toxic Compounds, Packaging, Storage

The rule would also establish a general prohibition on any coatings that contain more than 0.1% by weight of ozone-depleting compounds. That ban takes effect Jan. 1, 2012, although products may continue to be sold until Jan. 1, 2013. Again, virtually all coatings products currently in distribution already meet this limit, Berry stressed.

One practice that would go away, beginning July 1: the sale of multi-pack bundles of quart or liter cans of higher-VOC products. These containers have traditionally enjoyed a “small-container exemption,” but large quantities could be sold by bundling multiple cans in “contractor packs.”

The clock is also ticking on the longstanding practice of “storing” high-VOC coatings at work sites. Berry said inspectors have encountered some contractors who keep large quantities of high-VOC coatings at a work site, claiming that they will be using it at a job outside the region. The inspectors later return to find the coating in use at the site.

“We want to make sure that we have a clear, explicit enforcement mechanism” against such practices, Berry said.

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Comment from Michael Silverman, (1/31/2011, 3:42 PM)

Here are the comments I plan to send to the SCAQMD thru my company:
Section 27
HIGH-TEMPERATURE INDUSTRIAL MAINTENANCE COATINGS
EXISTING
COATINGS are industrial maintenance coatings formulated for or applied to substrates exposed continuously or intermittently to temperatures above 400 degrees Fahrenheit.
PROPOSED
COATINGS are industrial maintenance coatings formulated for or applied to substrates exposed continuously or intermittently to temperatures above 250 degrees Fahrenheit.
Section 28
INDUSTRIAL MAINTENANCE COATINGS
EXISTING (c) Repeated exposure to temperatures in excess of 250 degrees Fahrenheit
PROPOSED (c) Repeated exposure to temperatures up to 250 degrees Fahrenheit.
Commentary for changes:
The most commonly used Industrial Maintenance Coating is an epoxy of which there are several variations. These coatings, when formulated to 100 g/l or less typically have a maximum temperature limit of 250F. Above that temperature, technology does not exist to formulate organic epoxy coatings and still meet the 100 g/l rule. According to the current rule, High Temperature IM coatings which have a higher VOC limit, cannot be used until substrate temperatures exceed 400F. Therefore there is a gap between 250F and 400F where an IM coating system does not exist that is serviceable in that temperature range. Changing the language as noted above will close this technology gap and allow proper corrosion mitigation.
This change is particularly important for mitigation of corrosion under insulation, a big concern in the industry.